Employers are not required to collect, analyse or publish information on ethnicity pay. As part of our journey towards becoming an inclusive employer of choice we reported our ethnicity pay gap for the first time in 2024 based on a snapshot of our workforce on 31 March 2023.
The report is based on the government’s guidance for calculating differences in ethnicity pay and is based on a similar methodology as that used for gender pay gap reporting using electronic staff record (ESR) data. Information on ethnicity is not completed for all employee records, on 31 March 2023, 8 per cent of employee records had no ethnic origin recorded on ESR. Employees can update this information and there has been some improvement in recorded information in 2023/2024, with the numbers of records without details reducing to 5.6 per cent.
It is important to note that a pay gap differs from equal pay for equal work.
‘Equal pay’ means being paid equally for the same/similar work.
‘Pay gap’ is the difference in the average pay between groups.
The ethnicity pay gap shows the difference in the average hourly rates of pay for BAME employees (recorded in ESR as black, Asian, mixed race or other) and white employees across our organisation.
As of 31 March 2023, NHS Kent and Medway Integrated Care Board’s (ICB) 727 employees were 17 per cent BAME and 75 per cent white.
Our median ethnicity pay gap was -1.8 per cent.
Within this, we have a pay gap of -1.8 per cent for black staff, -1.8 per cent for mixed race staff, -1.4 per cent for Asian staff (data only provided for groups of over 10 employees)
A median pay gap of -1.8 per cent, means that on average BAME employees get paid 8p more per hour for every £1 earned by a white employee. This is mainly attributable to a higher proportion of BAME employees being paid in the upper quartile of earnings in our organisation.
Table 1 shows our workforce divided into four equal-sized groups based on hourly pay rate. Group 1 includes the lowest paid 25 per cent of employees (the lower quartile) and group 4 covers the highest paid 25 per cent (the upper quartile). NB. BME is used in ESR reporting – it includes all employees referred to as BAME in NHS Kent and Medway ICB.
What contributes to our ethnicity pay gap?
National reporting of ethnicity pay gap by ONS has recently been adjusted for the effect of occupation on earnings and they have identified that ethnicity differences in occupation can often mask a real ethnicity pay gap. For NHS Kent and Medway, the high proportion of medical staff in our workforce in Group 4 and the higher representation of BAME colleagues in the medical workforce (reflective of the national position) impacts our ethnicity pay gap.
We await further advice from NHS England and national improvements in ESR reporting to enable further analysis at occupational level.
How do we compare?
Nationally the ONS reports on ethnicity pay gaps by ethnicity breakdown. This data can be accessed on the Office for National Statistics website. It is not easy to directly compare with other organisations, however, the Nuffield Trust undertook research in 2021 which identified that for NHS staff in England employed under Agenda for Change there was no significant gap between white and ethnic minority staff. They reported a variance in pay gaps based on specific ethnic groups and outside of Agenda for Change. Further information can be found on the Nuffield Trust website.
What are we doing?
This year we will take the following steps to promote diversity and understanding barriers to promotion and recruitment for BAME colleagues:
- creating an evidence base: To identify barriers to equality and to help us make priorities for action, we have introduced diversity monitoring to understand:
- the race of those applying for jobs and being recruited;
- the race of those applying for and getting promotions;
- the race of those leaving our organisation and their reasons for leaving;
- the race of those in each role and pay band; and
- the race of those formally involved in disciplinary, grievance and capability matters. The initial findings will be published in July 2025.
- reviewing our disciplinary and grievance processes: to support a move towards a just and learning culture
- discuss the findings from our ethnicity pay gap alongside our equalities workforce analysis without our BAME network to get qualitative feedback on our organisation and the experience of our BAME employees, and to work collaboratively to develop initiatives to address issues identified.
I, Rebecca Bradd, Chief People Officer, confirm that the information in this statement is accurate.
Signed: Rebecca Bradd
Date: 31 March 2024